International Reservation of Title Clauses:A Study of Dutch, French and German Private International Law in the Light of European Law

The rules of substantive law relating to the reservation of title clause differ from country to country. This book addresses problems which may arise if a reservation of title clause is employed within international transactions, especially transactions between Germany, France, and the Netherlands. The author seeks the solution in private international law, since other means of addressing the problem, such as harmonization and unification of substantive law rules, have failed so far. This study makes an important contribution to the understanding of European integration in a hitherto relatively neglected area.